Response 519280820

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Questions

1. Do you agree that Scottish vessels required to use REM in the Scottish zone should also have REM operational when operating outside of the Scottish zone?

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Yes
No
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NESFO is of the opinion that the use of REM should be on a level playing field basis and that all vessels operating in and outside the Scottish zone should be subject to the rules and regulations of the relevant fishing areas.

2. Do you foresee any barriers to vessels meeting the costs associated with the REM systems themselves? This includes upfront and ongoing costs.

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Yes
No
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This is a further levy to the industry and at the moment fishing businesses are struggling economically with the high rise of costs in fuel, gear etc. If this is a mandatory regulation Government should meet all the upfront and ongoing costs associated with Remote Electronic Monitoring.

3. Are you aware of any issues we need to take account of when we apply REM across all pelagic fishing fleets fishing in Scottish waters on a level playing field basis?

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No Comment

4. Do you agree with the definition of pelagic vessels provided and are there any unintended consequences from using this definition?

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No Comment

5. How much lead-in time should pelagic industry be given to prepare for compliance with the mandatory REM requirement?

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No Comment

6. Do you agree with the scientific and compliance benefits of REM for the pelagic fleet as set out in this document? Are there other benefits which you can consider, including to industry, the environment, or local communities?

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No Comment

7. Do you agree that the system as outlined in section 3.4.2 (System specification) should be able to meet the benefits described in Section 3.3?

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No Comment

8. Do you foresee any specific operational problems with the system specification set out within the document?

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No Comment

9. Do you believe that we should require net sensor data as part of the system specification at this point?

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No Comment

10. Are you aware of any issues we need to take account of when we apply REM requirements consistently across all scallop dredge vessels in the Scottish zone, regardless of scallop species being targeted or number of dredges being deployed?

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No Comment

11. Do you agree that REM requirements on vessels carrying and/or deploying scallop dredge gear in the Scottish zone should be broadly aligned to existing REM requirements provided for in Regulation 6 of the 2017 Order?

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No Comment

12. Do you consider that any other changes (in addition to the ability to record footage to a minimum of 5 Frames per Second) should be made to the REM system specification?

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No Comment

13. What is your view in relation to the various options outlined for deployment of REM to parts of the demersal fleet as outlined in Section 5: REM for large demersal vessels ?

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As stated in a previous answer there must be a level playing field and all vessels fishing within Scottish waters must be equipped with REM. There are already alternative options that industry are participating in at the moment such as the Real Time Reporting Scheme in the West of Scotland, this scheme could be expanded and be a valuable tool in collecting scientific data and informing participants of areas to avoid unwanted catches. The alignment between scientific data and industry will be key towards achieving an increase in compliance with legislation and result in delivering confidence and accountability to the consumers and members of the public.

14. Taking into account the Business Regulatory Impact Assessment (BRIA) supplementing this consultation, do you have any comments or views which you would like to put forward?

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No Comment

About you

What is your name?

ANNE BIRNIE

Are you responding as an individual or an organisation?

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Individual
Organisation

What is your organisation?

NESFO Ltd